PRIVACY POLICY

Date of implementation: June 2020

GENERAL

We (hereafter referred to as “the Company,” “We,” “Us,” and the like) are strongly devoted to regulatory compliance, as well as the privacy and security of personal data. As a result, the Users (hence, individually referred to as “the User”, “the Customer”, and collectively referred to as “you”, “your”) of this website will find all necessary information in the current Privacy Policy to better understand what we do with their personal data.

We may amend our Privacy Policy in response to new statutory or judicial requirements, as well as business reasons. Any change or modification to the current Privacy Policy will be effective as of the day it is published on the website. As a result, the User is advised to examine our Privacy Policy on a frequent basis.

Please keep in mind that in order to access and use our website, you must be an adult with the legal ability to enter into contracts under your place of birth and/or residence’s applicable national laws and regulations.

The current Privacy Policy is not contractual or part of your contract with us, but it does not impact your rights under current relevant legislation.

WHAT DOES PERSONAL DATA MEAN?

Personal data is any information that identifies you or might be used to identify you, such as your contact information (your complete name, date and place of birth, email/postal address, and signature) and/or other information such as how you use our website or your IP address.

WHEN DOES THIS PRIVACY POLICY APPLY?

This Privacy Policy applies to the personal data we collect, use, and process from you as a User and/or Customer of our website.

Our website may include icons and/or links that will take you to third-party websites. Because we have no control over these third-party websites, we cannot accept responsibility for the information and material supplied on them, as well as the accurate supply of the features and/or services offered by these third parties. Third-party websites are subject to their own Cookie and Privacy Policies.

WHAT PERSONAL DATA DO WE COLLECT?

The personal data we collect from and about you is as follows:

• Direct interactions: Data collected when you interact with us by completing the forms on our website (such as the Electronic Travel Authorization application form or the Contact form) and/or when you contact our Customer Service Team by the enabled means, such as the website’s chat, post, email or telephone.
• Automated technologies: We may automatically collect information like your IP address, the sections you consult on our website, or the amount of time that you spend on our website by using cookies, whether our own or from third parties. You can consult our Cookie Policy to obtain more information about the cookies on our website, their purposes, and other information of interest.

Please be informed that you will only be required to provide the personal data and information that is strictly necessary to fulfill the purposes explained below. Therefore, if you provide us with more information than the one expressly required, you consent to its processing for the informed purpose/s for which you are sending it.

In order to successfully submit his/her Electronic Travel Authorization application and/or manage his/her information and/or support request, the User must supply accurate, up-to-date, and complete personal data and/or private information. We shall not accept any liability for events beyond our reasonable control, such as the User providing incorrect, incomplete, and/or fraudulent information.

If you provide us with personal information about third parties, whether minors or adults, you guarantee that you have informed them about the purposes for which their personal information will be processed by the Company and that you have obtained their prior and express consent to communicate us their personal information.

If you give us with a minor’s personal information, you confirm that you are his/her parent and/or legal guardian.

Please keep the following in mind:

• if the Company has received an adult’s personal data and/or private information to submit his/her Electronic Travel Authorization application from an individual who has not requested his/her consent to communicate us his/her personal data, the Company will inform the data subject of how his/her personal data and/or private information has been collected. Moreover, where appropriate, we will ask the individual who provided the personal data to the Company to confirm whether he/she requested the consent of the data subject and, if necessary, to amend this circumstance. In any case, the data subject will have at all times the possibility of objecting the processing of his/her personal data by the Company, in which case the provision of our professional services will not be possible, so that submission of the Electronic Travel Authorization application will be canceled.
• if the Company has received a minor’s personal data and/or private information to submit his/her Electronic Travel Authorization application from an individual who is not his/her parent and/or legal guardian, as soon as the Company detects and/or becomes aware of these circumstances, it will proceed to take the appropriate measures to fix the situation, including the possibility of canceling the submission of his/her application.

WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

We only process your personal information when we have a legal basis to do so. The legal basis will be determined by the reason for collecting and processing your personal data. The legal foundation will nearly always be:

• To fulfill the contract with you, meaning, to check the accuracy of your Electronic Travel Authorization application form and submit it before the Government; to keep you updated regarding the status of your application and communicate to you the Government’s final decision regarding its approval or denial; to respond to your information requests addressed to our Customer Service Department, among others.
• The consent that you provided us with for the processing of your personal data in connection to the purposes communicated at the time of collection of your data (i.e. to receive the requested information by writing to our Customer Service team).
• For compliance with our legal obligations and/or to satisfy the requirements of administrative, judicial, police or corresponding authorities.
• Our legitimate interest regarding (i) credit/debit cards and other methods of payment verification, (ii) address possible claims regarding our services, (iii) enhancing the user experience when you use this website and to operate it efficiently, (iv) enhance the quality of our professional services, (v) monitor fraudulent activity in order to preserve the security and integrity of our website.

HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will process your personal data for as long as it is required to meet the reasons for which it was obtained, and then your personal data will be maintained, suitably securely blocked, for the time period required. For example, it will be kept for as long as necessary to comply with our legal obligations and/or address potential claims related to the professional services we have provided; to complete the investigation of a detected fraudulent or illicit activity; to retain the Cookies’ information if you do not revoke its consent, and so on. Your personal data will be safely removed from our information systems once the required retention term has expired.

Furthermore, if you have given us your approval to handle your personal data for certain reasons, please keep in mind that you can withdraw such consent at any time. We will destroy your personal data after we receive your withdrawal request.

WITH WHOM WO WE SHARE PERSONAL DATA?

Your personal information will be processed and/or shared in the following situations:

• To the Government of the country you’re going to visit as it is the competent body to approve or deny the Electronic Travel Authorization applications.
• To our payment service providers to process the payment of the costs related to the Electronic Travel Authorization application process and to carry out fraud controls, as well as to your bank entity credit/debit card companies when you have initiated a dispute of the charges made.
• To our technology service providers which host our information systems and/or that offer us tools or technological support.
• To comply with our legal obligations and when administrative, judicial and/or police authorities require it in accordance with the applicable law and regulations.
• To protect our legitimate interests in the event that a claim may arise regarding the professional services offered.

Because the aforementioned third parties may have their headquarters outside of the European Economic Area, the personal data will be subject to international transmission. In this regard, we inform you that we only transfer personal data to recipients located in countries that provide a level of personal data protection comparable to European data protection laws and regulations, or, failing that, we will apply the appropriate safeguards required by current applicable law and regulations on the protection of personal data, in order to ensure the privacy and security of your personal data, as well as the protection of your individual rights.

HOW DO WE PROTECT YOUR PERSONAL DATA?

Your personal data is securely stored in our information systems, and we have put in place the necessary technical and organisational safeguards to ensure the confidentiality and integrity of your personal data, as well as to protect it from unauthorised or unlawful processing and/or accidental loss, destruction, or damage.

Similarly, we have taken reasonable steps to ensure that all of our employees, as well as any suppliers or partners who have access to your personal data, have received adequate information and/or training about their obligations regarding the processing of personal data of our Users and/or Customers to which they have access for the previously mentioned purposes.

Although we will do our best to protect your personal data transmitted through our website and/or that you may provide us with via other means such as email or phone, please keep in mind that you must also take precautions to keep your personal data safe, such as not entering or confirming bank details through fake messages and/or websites.

WHAT RIGHTS DO YOU HAVE AND HOW CAN YOU EXERCISE THEM?

You may exercise your rights to access, correction, deletion, limitation of processing, objection, and portability of your personal data by sending us a written request through email to [email protected] or using our Contact Form.

You may change your web browser’s “privacy settings” at any moment to enable tracking cookies. You may also install apps or browser add-ons known as “Do Not Track” utilities that allow you to select which Cookies to accept.

Your request for data protection rights will be answered to within one (1) month; however, this period may be extended by two (2) months if required, taking into consideration the complexity and/or quantity of requests you may have made. In this situation, we will advise you of the extension as well as the cause for the delay.

If you believe it is appropriate, you have the right to file a complaint with the respective Supervisory Authority, for example, if you believe your data protection rights have not been sufficiently met.

We are available to answer any questions or concerns you may have concerning the current Privacy Policy or the processing of your personal data, so please contact us at [email protected].